The parties request that the status conference in this case be continued from March 24, 2011 to April 28, 2011 at 9:00 a.m. They stipulate that the time between March 24, 2011 and April 28, 2011 should be excluded from the calculation of time under the Speedy Trial Act. 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant has reasonable time necessary to discuss the Government's offer of resolution with the defendant.

Although it was anticipated this could be accomplished prior to March 24, unfortunately the defendant has continued to be ill and the medications given to him precluded meaningful discussion with him regarding entry of a plea. It is essential of course to review the plea agreement with defendant so that he completely understands the parameters of the agreement in preparation for the expected change of plea hearing. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

Respectfully Submitted, THE ROSENFELD LAW FIRM

SO ...

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